G.R. No. 54281 , March 19, 1990
CELSO PAGTALUNAN and PAULINA P. PAGTALUNAN, petitioners, vs. HON. ROQUE A. TAMAYO, Presiding Judge of the CFI of Bulacan, Branch VI, REPUBLIC OF THE PHILIPPINES and TURANDOT, TRAVIATA, MARCELITA, MARLENE PACITA, MATTHEW and ROSARY, all surnamed ALDABA, respondents.

FACTS

The Republic of the Philippines filed a complaint for expropriation of a parcel of land in Malolos, Bulacan, owned by the private respondents Aldaba. The trial court issued a writ of possession. Petitioners Celso and Paulina Pagtalunan filed a motion to intervene, alleging that Celso was the bona fide agricultural tenant of a portion of the land. They sought payment of just compensation for his landholding or, alternatively, disturbance compensation as a tenant. The respondent judge denied the motion, ruling that allowing the intervention would be tantamount to permitting a suit against the State without its consent, as the claim for disturbance compensation was a claim against the State.
Meanwhile, the Republic appealed the trial court’s decision on the valuation of the land. The trial court dismissed the appeal as filed out of time, a ruling eventually overturned by the Supreme Court in a separate petition ( G.R. No. 54886 ), which directed the trial court to approve the record on appeal. The petitioners in this case filed the instant petition challenging the denial of their intervention.

ISSUE

The principal issue is whether the trial court correctly denied the petitioners’ motion for leave to intervene in the expropriation proceedings.

RULING

The Supreme Court denied the petition, upholding the trial court’s order. Intervention is not a matter of right but rests on the applicant showing a direct, material, and legal interest in the matter in litigation. The Court held petitioners failed to establish such an interest. Their claim to just compensation was based on a Certificate of Land Transfer (CLT) issued under P.D. No. 27, which describes the grantee as “deemed owner.” The Court clarified this phrase does not confer full legal title but indicates a promise of ownership contingent upon full payment of amortizations. Since the petitioners had not fully paid, they remained mere holders of an inchoate right, not owners entitled to compensation from the expropriation proceeds, which properly belonged to the registered owners, the Aldabas.
Alternatively, the claim for disturbance compensation under the Agricultural Land Reform Code ( R.A. No. 3844 ) was also unavailing. The right to such compensation arises when the landowner- lessor voluntarily converts the land use. Here, the conversion was effected by the State through expropriation, independent of the landowners’ will. The government had already compensated Celso Pagtalunan for improvements and relocation expenses. Consequently, petitioners possessed no actual, direct interest justifying intervention. The ancillary issue on jurisdiction was rendered moot by Batas Pambansa Blg. 129, which vested exclusive original jurisdiction over such matters in the Regional Trial Courts.